Key implementation point
0% rate jurisdiction. Major private equity and fund domicile — QDMTT applies to non-excluded fund manager and holding entities meeting revenue threshold.
Implementation detail
- 01 Guernsey enacted QDMTT effective 1 January 2025.
- 02 Standard CT rate is 0% for most companies (20% for banking, regulated utilities).
- 03 QDMTT critical: Guernsey has a large fund and fiduciary sector; qualifying entities face QDMTT top-up.
- 04 Revenue Service issued guidance.
- 05 Guernsey is a significant domicile for private equity funds and holding structures.
Enacted legislation
The Income Tax (Pillar Two) (Guernsey) Law 2024
Official sources & further reading
Track Guernsey rules against your live MNE
In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.
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